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| The Tax Publishers2020 TaxPub(DT) 0734 (Del-Trib) INCOME TAX ACT, 1961
Section 147 Section 154
As issue in two proceedings initiated under section 154 as well as under section 147 was the same, AO without concluding the proceeding under section 154 could not initiate parallel proceeding under section 147/148.
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Reassessment - Validity - Initiation of proceedings under section 147/148 - When proceedings under section 154 were pending on the same issue
AO initiated reassessment proceeding under section 147/148, when proceedings under section 154 were pending on the same issue. Held: As issue in the two proceedings initiated under section 154 as well as under section 147 was the same AO without concluding the proceeding under section 154 could not initiate parallel proceeding under section 147/148.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12
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